Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Validity of re-assessment proceedings - UP VAT - It is only on the basis of the fact that the royalty amount has not been clarified in the invoices that a decision has been taken to reopen the assessment. This by itself is not sufficient and a good ground when the assessing authority was possessed with all material at the time of initial assessment and nothing material was concealed from him. - HC
Validity of re-assessment proceedings - UP VAT - It is only on the basis of the fact that the royalty amount has not been clarified in the invoices that a decision has been taken to reopen the assessment. This by itself is not sufficient and a good ground when the assessing authority was possessed with all material at the time of initial assessment and nothing material was concealed from him. - HC
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